Avionics News January 2014 - 17

dure (AP or APDOA) does work well and is appreciated by the
industry. Of course, numerous changes in the system and the
development of new systems, products and processes require
the stakeholder to speed up their evaluation, implementation
and adjustment to the latest standards.
The success of the DOA process is indicated by the number of growing DOAs throughout the past 10 years. At the
EASA introduction in 2003, there were 52 DOAs originating
from prior EASA times (JAR-21 DOAs), which grew until
November 2013 to the impressive number of 297. The number
of APs grew at the same time to 265.
Next to the other topics, probably the most important information for EASA DOAs are the new level of involvement and
flight testing regulations for aging aircraft structures.

Level of Involvement
The LOI is identified as a "selection of the compliance demonstration items that the agency will investigate and the depth
of those investigations." In other words, how much time and
effort the agency will spend on the DO-provided documentation
for the approval of STCs.
With the implementation of ICAO Annex 19 and the transposition into EASA rulemaking, the agency intends to introduce a
risk-based approach for the review of DOs-provided STC documents. "Risk" in this context is the risk that the STC project for
a certain topic is not properly or completely exercised and may,
therefore, create a risk when installed on an aircraft.
The EASA plan is to introduce a new LOI based on the following criteria:
*
*
*

Novel or unusual features.
Safety risks on similar design.
Performance of the DO.

EASA has started to evaluate sample major change
projects from identified TC holders, but is also evaluating
the performance of other DOA holders in the context of
STC projects to identify how well the system works. Such
evaluation and feedback is provided by the involved EASA
certification experts. In the already ongoing test phase,
such evaluations are not transparent, and the outcome is
not available to the evaluated company.
Below is a matrix proposed for the LOI in upcoming
regulations.
The schedule for implementation was indicated as follows. The NPA to the new rule was planned to be issued
December 2013 with the opinion issued by second quarter
of 2014. The NPA for the AMC and GM is expected no
earlier than third quarter of 2014. This seems to be a rather
aggressive timeframe for such a complex and important
new regulation, and we are expecting some delays in the
implementation schedule.

Considering a similar implementation time of SMS as
in the maintenance section, the above schedule would provide a full implementation of the system no earlier than
2016, if not 2017.
Industry representatives have indicated that the expert
feedback and the level of performance must be visible to
the applicant.

Flight Testing
Following the implementation of the Opinion 07/2013,
which will likely be early 2014, EASA and the affected DOs
will be introducing the new concept of flight testing with the
more extensive requirement to introduce a flight test operations
manual, which is a detailed handbook on how flight tests are to
be conducted. As part of this new standard, new regulations on
the qualification of flight test crew (pilots and lead engineers)
qualifications will be implemented.
The implications are wide reaching. EASA has identified the
need to introduce a license for a lead flight test engineer. The
flight test pilot licensing is being implemented in an amended
EASA-FCL (flight crew license) regulation. A few countries
had a similar system in place prior to the new rule, but for most
other countries and organizations, this is a new requirement and
will need the individual organization to establish and improve
the level of competence or identify equivalent qualification. The
competence training required to perform Category 1 or 2 flights,
which include flight or handling characteristics, general aircraft
behavior, basic crew procedures, beyond approved limitations,
performance or flight envelope verifications will be included in
a detailed syllabi provided in the AMC (see CRD to NPA 200820) to the rule.
Note: Competence Level 3 is for post TC or STC flight
testing.
The newly introduced FTOM will have to detail the processes used for flight test, crewing policy and the carriage of other
persons, flight time limitations and flight test training requirements (initial and recurrent). Since flight testing is an integrated
part of the design process, it also will be subject to the SMS
system, which will require it to be covered by a safety risk management process.
The schedule for the implementation provided by EASA is as
follows:
*
*
*

Entry into force late 2014.
Competence and experience requirements entry into
force +36 months.
FTOM not later than 12 months after the entry into
force.

All the presentations are available on the EASA website.
Continued on page 65

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2014

Avionics News January 2014

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